10.20—Information to be furnished.
(a)
To the Internal Revenue
Service. (1) A practitioner must, on a proper
and lawful request by a duly authorized officer or
employee of the Internal Revenue Service, promptly
submit records or information in any matter before
the Internal Revenue Service unless the
practitioner believes in good faith and on
reasonable grounds that the records or information
are privileged.
(2)
Where the requested records or information
are not in the possession of, or subject to the
control of, the practitioner or the practitioner's
client, the practitioner must promptly notify the
requesting Internal Revenue Service officer or
employee and the practitioner must provide any
information that the practitioner has regarding
the identity of any person who the practitioner
believes may have possession or control of the
requested records or information. The practitioner
must make reasonable inquiry of his or her client
regarding the identity of any person who may have
possession or control of the requested records or
information, but the practitioner is not required
to make inquiry of any other person or
independently verify any information provided by
the practitioner's client regarding the identity
of such persons.
(b)
To the Director of the Office of
Professional Responsibility. When a proper and
lawful request is made by the Director of the
Office of Professional Responsibility, a
practitioner must provide the Director of the
Office of Professional Responsibility with any
information the practitioner has concerning an
inquiry by the Director of the Office of
Professional Responsibility into an alleged
violation of the regulations in this part by any
person, and to testify regarding this information
in any proceeding instituted under this part,
unless the practitioner believes in good faith and
on reasonable grounds that the information is
privileged.
(c)
Interference with a proper and
lawful request for records or information. A
practitioner may not interfere, or attempt to
interfere, with any proper and lawful effort by
the Internal Revenue Service, its officers or
employees, or the Director of the Office of
Professional Responsibility, or his or her
employees, to obtain any record or information
unless the practitioner believes in good faith and
on reasonable grounds that the record or
information is privileged.